When two women ascended to the Supreme Court of Minnesota, Catharine MacKinnon asked, “Will they use the tools of law as women, for all women?” She continued as follows:

Urging judges to “use the tools of law as women, for all women” alarms universalist philosophers. These are the philosophers who think that moral theory should come up with principles that mention no group smaller than “persons” or “human beings” or “rational agents.” Such philosophers would be happier if MacKinnon talked less about accountability to women as women and more about an ideal Minnesota or an ideal United States, one in which all human beings would be treated impartially. Universalists would prefer to think of feminism as Mary Wollstonecraft and Olympe de Gouges did, as a matter of rights that are already recognizable and describable, although not yet granted. This describability, they feel, makes MacKinnon's hope for a voice saying something never heard before unnecessary, overly dramatic, hyperbolic.